REACH PLC - PRIVACY NOTICE

WHO WE ARE

We are the publishing group Reach plc.

In this Privacy Notice, when we refer to any of our Sites we mean
any website or app, including e-editions, published by our various
subsidiary companies and brands, listed here
(“Reach Group” or “we”), regardless of how you access it.

ABOUT THIS PRIVACY NOTICE

This is the main privacy notice for the Reach Group. It
applies to all our Sites, and brands, but some of them may publish
additional or alternative notices, in which case those take precedence.

In summary, depending on your relationship with us, we’ll use your
personal information:

As needed to provide our products and services, for example to
administer subscriptions, take orders and ad placements and handle
customer service queries

To provide the interactive features of our Sites, such as
commenting, discussion forums and competitions

To display advertising on our websites that is more likely to be
relevant to you, and to participate in online advertising networks by
sharing information about the kinds of people who visit our Sites, in
order to help us to fund those Sites and keep the majority of them free
to access. Information gathered in this way does not identify you
by name.

To manage our business and to comply with the law.

This Privacy Notice, which covers all of your personal information
whether collected online or offline, including by telephone or where
you write to us, together with our Cookie Notice and any Site-specific
notice, provides more detail on those activities and explains your
rights and how to exercise them.

For all of our Sites, and brands, either Reach plc or one of its
subsidiary companies is the data controller of the personal information
that we gather about you. Regardless of which Reach Group company
is the controller, you can always contact us with questions or concerns
about your privacy by emailing us at dataprotection@reachplc.com

1. TYPES OF INFORMATION WE PROCESS AND WHERE IT COMES FROM

Information that we collect and process about you includes:

Personal and contact details you have provided to us, such as
your name, email address or postal address, for example when you
register on a Site or to receive a newsletter, enter a sales promotion
or competition, or at an Event, or where you have agreed to receive
marketing materials from us or third parties;

Information you have provided when you obtain products or
services from us or enquire about those products or services;

Information included in any communications between us or which
you provide in any post on any Site or any information collected when
you participate in any poll or quiz or obtained via social media or
which is publicly available;

Information about your use of third party products or services or
from third parties who we may use to operate certain aspects of our
business;

Information obtained if we carry out a credit search at a credit
search referencing agency;

Information we buy or obtain from third parties, including
marketing lists; and

We also collect information from cookies on your devices and this
includes information about your IP address, MAC address and other
identifying information, information about your devices, including your
location, from third party advertising networks and how you use our
products and services.

We want to offer you products and services which you want to use. We
may use and permit others to use your personal data as set out below.

We may use information about you to provide and manage the products
and services you have subscribed to or purchased, to help us customise
our products or services for you, to personalise your visits to our
Sites, to help us to choose products and services we think will
interest you, for market research and to improve the usefulness of our
Sites, products and services.

We also use your personal data to contact you, including to notify
you about changes and updates to products or services, to evaluate the
performance of our products and services and to develop new products
and services.

We may use your information for the management of our business and
improving the operation of our business and that of our business
partners, to assess our internal processes and carry out financial
checks.

We may monitor, record and store records of calls, email, text
messages, social media messages, in person meetings and other
communications where permitted by law and we’ll do this where the law
requires it, or to comply with regulatory rules, to prevent or detect
crime, for evidential purposes, in the interests of protecting the
security of our communications systems and procedures and for quality
control and staff training purposes.

We may use your data to comply with legal and regulatory obligations.

We may make use of your personal information for direct marketing
activities, or supply this information to third parties for their
direct marketing activities, with your consent or as permitted by law.
By direct marketing activities, we mean the communication directly to
particular individuals (by e-mail, post or telephone) of any
advertising or marketing material.

Where we’re relying upon your consent to process personal data, you
can withdraw this at any time by contacting us at dataprotection@reachplc.com.

Information about you helps us sell advertising to businesses of
products and services relevant to you so that we can continue to fund
these through advertising and you can continue to use the majority of
our websites for free.

We may analyse your data, including whether or not you open a
newsletter or click on links, and analyse data, gathered thorough our
websites and advertising partners, including by analysing your data in
aggregated form into categories (known as segments), to help target
offers to you that we think are of interest or relevance to you. You
can find more information on this in our Cookie
Notice.

We may disclose details about the use of the Sites to other
businesses e.g. to demonstrate patterns of use to advertisers and
others. The information we pass on will be anonymised. We compile
anonymous records of user trends which we may make use of ourselves or
pass to our associated companies, including advertising networks. You
can read more about this in our Cookie Notice.

3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share information as needed with our third party service
providers and partners, to other members if the Reach Group, as part of
providing and administering our products and services or operating our
business or as set out below.

We will disclose your information and co-operate with appropriate
bodies and authorities in good faith where we are required to by
law, a court order, a regulatory authority, or otherwise, including
with the police, trading standards, regulatory authorities or other
relevant authorities.

We may share information about you with credit reference agencies.

We may also share information to facilitate the sale of one or more
parts of our business, including if we are approached by a potential
buyer or the restructuring of one or more parts of our business and
with auditing organisations such as the Audit Bureau of Circulation

4. COOKIES

We collect information about you automatically when you visit our
Sites by using cookies (small text files) and other tracking
technology. For more information about cookies, and other tracking
technology including how to turn them off, please see our Cookie Notice.

5. TRANSFERS OUTSIDE OF EUROPE

We’re based in the UK and the Republic of Ireland but sometimes your
personal information may be transferred outside the European Economic
Area. If we do so we’ll make sure that suitable safeguards are in
place, for example by using approved contractual agreements, unless
certain exceptions apply. We can provide more information about
this on request.

6. WHAT ARE THE LEGAL GROUNDS FOR OUR PROCESSING OF YOUR
PERSONAL INFORMATION (INCLUDING WHEN WE SHARE IT WITH OTHERS)?

We rely on the following legal bases to use your personal data:

A. Where it is needed to provide you with our products or
services, such as:

Managing products and services you hold with us, or an enquiry
about
one

Updating your records, tracing your whereabouts to contact you
about
your account and doing this for recovering debt (where appropriate)

Sharing your personal information with third parties and services
providers when you apply for a product or service to help manage your
product or service

All stages and activities relevant to managing any product or
service including enquiry, application, administration and management
of accounts

For some direct marketing communications, subject to appropriate
controls and safeguards

To follow guidance and recommended best practice of government
and
regulatory bodies

For management and audit of our business operations including
accounting

To carry out monitoring and to keep records of our communications
with you and us

To administer our good governance requirements and those of other
members of our Group, such as internal reporting and compliance
obligations or administration required for AGM processes

For market research and analysis and developing statistics

To provide insight and analysis of our customers to business
partners either as part of providing products or services, helping us
improve products or services, or to assess or to improve the operating
of our businesses

Where we need to share your personal information with people or
organisations in order to run our business or comply with any legal
and/or regulatory obligations

To comply with our legal obligations or where we reasonably
believe
we are under a legal or regulatory obligation

C. With your consent or explicit consent

For some direct marketing communications and digital advertising
activities

For some of our processing of special data categories of personal
data such as about your health

7. HOW LONG DO WE KEEP YOUR DATA FOR?

In general, we keep your personal information for as long as we need
it for the purpose for which it was collected, plus a short additional
period in case of problems. How long we keep it therefore varies
according to the type of information it is and why we have it, and will
range from a few days or weeks to, in some cases, several years.
We have established a full data retention policy, and can provide
further information on request.

8. WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LAW?

The law gives you certain rights in respect of the information that
we hold about you. Below is a short overview of those rights. The
website of the Information Commissioner’s Office (http://www.ico.org.uk) has a wealth
of useful information in respect of your rights over your personal data.

If you wish to exercise your rights, you can write to us by
email dataprotection@reachplc.com
or by post to Reach plc, One Canada Square, London E14 5AP, for
the attention of the legal department.

Your right to withdraw your consent

If we are processing your personal data on the basis of your
consent, you have the right to withdraw that consent at any time.

Your right to access the information we hold about you

With some exceptions designed to protect the rights of others, you
have the right to a copy of the personal data that we hold about you,
as well as information about what we do with it, who we share it with
and how long we will hold it for. We may make a reasonable charge
for additional copies of that data beyond the first copy, based on our
administrative costs.

Your right to have inaccurate information about you
rectified

You have the right to have the information we hold about you
corrected if it is factually inaccurate.

Your right to object to what we do with your data, and
to have restrictions placed upon it

Where we process your personal data on the basis of our legitimate
interest, you have the right to object to that processing and to have
restrictions placed upon it while we consider your objection.

Your right to have your information erased in some
circumstances

You have the right to require us to delete the information that we
hold about you if it is no longer necessary for the purpose we
collected it for, and there is no other legal basis on which we must,
or are allowed to, retain it.

Your right to stop receiving direct marketing from us

You have the right to require us to stop sending you direct
marketing material (for example, promotional emails). It can
sometimes take a few days to action these requests.

Your right to complain to the Information Commissioner’s
Office (ICO)

You have the right to lodge a complaint about our handling of your
personal data with the supervisory authority, which in the UK is the
Information Commissioner’s Office. But before you do so, please do
contact us first to give us a chance to put matters right, at dataprotection@reachplc.com

You can contact the ICO on 0303 123 1113.

9. CHANGES TO THIS PRIVACY NOTICE

It’s likely that we’ll need to update this Privacy Notice from time
to time. Any changes to this Privacy Notice will be posted here
and such changes will become effective as soon as they are posted. Your
continued use of the relevant Site constitutes notice to you of all
these changes.

10. CONTACT US

If you have any questions about this privacy notice, or if you wish
to exercise your rights you can contact us email at dataprotection@reachplc.com.
Alternatively, you can write to the Legal Department, Reach plc, One
Canada Square, London E14 5AP